Companies Participating in the 2010/15 PFOA Stewardship Program
On October 11, 2006, EPA circulated its suggested guidance for emissions and product content reporting under the 2010/15 PFOA Stewardship Program. EPA has received some requests for additional clarification concerning elements of the guidance, and is sharing these clarifications with all of the participating companies to ensure that a common understanding is maintained.
The reporting guidance document and all clarifications are included in the Stewardship Program docket, EPA-HQ-OPPT-2006-0621.
Item #1: Definition of "precursors"
For the purposes of the PFOA Stewardship Program reporting forms, the term "precursors" applies to both PFOA precursors and to precursors of higher homologue acids. This definition is intended to be applied consistently throughout the guidance document. The precursors of higher homologue acids tend to be grouped with the higher homologue acids rather than with PFOA or PFOA precursors for reporting purposes, where the higher homologues are reported separately from PFOA -- for example, in the detailed data to be submitted to the Agency in support of the public reporting forms. Where PFOA and the higher homologues are reported in a combined fashion rather than being segregated -- for example, in order to preserve CBI in the public reporting context -- the precursors are also reported in a combined fashion.
Item #2: Ambiguity in Appendix D List of Chemicals
In the exemplary list of chemicals in Appendix D, chemical 2-propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl ester was listed as both a PFOA precursor and a higher homologue with two different CAS numbers. One of these listings was an error. The correct name for CAS. No. 4980-53-4 is 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,13,13,14,14,15,15,16,16,16-nonacosafluorohexadecyl ester, and this chemical should be listed in the higher homologue category.
Item #3: Preserving CBI in Appendix E and F
Under Section 3 in Appendix E and F, companies are asked to provide information regarding (i) the quantity of chemical released (by chemical category) and (ii) the quantity of chemical released (by chemical category) per kg of fluoropolymer and/or telomer produced. If reporting information for both fields (i and ii above) presents CBI concerns, then the Agency would prefer to receive in the public reporting form the actual quantity of chemicals released (by chemical category). However, it might be possible for the emissions ratio to be reported as a range in addition to reporting the actual emissions, without compromising any CBI information. If using this approach is feasible, the recommended ranges would be: (1) < 1%, (2) 1 to < 10%, (3) 10 to < 50% and (4) 50% and above.